You might be required to provide your non-financial promotions register during assessments.
Process
- QFA advisers can create their own non-financial promotions.
- These do not require submission for financial promotions or Marketing review but should be recorded in your own internal marketing register.
- QFA advisers will manage their non-financial promotions marketing register.
- Link to the non-financial promotions register that you need to manage and update here.
What is a non-financial promotion?
Advertising falling into the below categories would not typically be classed as a financial promotion:
- Non-business communications such as lifestyle posts, recruitment adverts, seminar invitations.
- Business to business such as presentations or ads to advisers or marketing services to other business rather than individual consumers.
- Factual information to inform or educate - provided it does not encourage the recipient to respond, provide an opinion, recommend any action, provide or offer advice or any additional information about the firm’s product or services. For example, a link to a news item such as ‘Bank of England holds interest rates at 0.5% (link to source)’ would not need pre-approval. Press releases will also generally fall into this category; however firms should be cautious to not include any type of inducement or invitation whether direct or indirect. Content should be factual and for information only purposes.
Please note that should any amendments be made to this item which would deem it to be a financial promotion, it would no longer be fit for use and should be taken offline or discarded.
Additional considerations:
Quilter Financial Advisers logo
You must not use the Quilter Financial Advisers logo in any of your marketing or communications unless this has been approved by the Quilter Marketing team.
Topics/content to avoid
Click here to view a list of topics that must be avoided in any of your promotional activity.
What is a financial promotion?
FCA definition: “An invitation or inducement to engage in investment activity or to engage in claims management activity that is communicated in the course of business”. Therefore, anything that persuades, invites, or leads something to do something, and exaggerated commendation for promotional purposes e.g., terminology/general sales pitch will be deemed a financial promotion.
REMEMBER: A call‐to‐action button (e.g., contact us) is not always the trigger. For more info refer to the Financial promotions hub.